AVMA responds to Federal Register request for comments.

The Public Health Action Plan to Combat Antimicrobial Resistance, (Action Plan) developed by an interagency Task Force on Antimicrobial Resistance in 1999, reflected a broad-based consensus of federal agencies and other stakeholders on actions needed to address antimicrobial resistance (AR).

The AVMA was a key stakeholder in the development of the Action Plan, helping to ensure that the plan provided a blueprint for detailing coordinated federal actions that are critically needed if we are to mitigate the threat of AR: Surveillance, Prevention and Control, Research, and Product Development. Since the development of the Action Plan, the AVMA has consistently been supportive of the plan and advocated for funding to fully implement the plan.

The AVMA applauds the Interagency Task Force and its collaborators for advancements made in combating AR. We assert, however, that upon publication of annual progress reports, inclusion of status updates regarding completed, current, and new projects would allow a more comprehensive view of the successes gained and barriers encountered in implementing the Action Plan.

While we appreciate the efforts of the Interagency Task Force to embark upon the complex issues of AR, the AVMA has three main concerns regarding the implementation of the Action Plan:

• We contend that this Action Plan represents precisely what is needed to tackle the threat of AR, yet the animal and veterinary components of the plan have been continually underfunded.
• Of the original 13 Top Priority Action Items (please see full AVMA response below), few actions have targeted animal health or yielded results that can mitigate AR in animals, and therefore transmission to humans.
• Other Action Items that target animal health still require additional funds and efforts for full implementation.